Iso 22000 Comments

Here goes.

Admin:

Split from December 03 update and pinned to make it easier to find.
http://www.saferpak....p?showtopic=820

Regards,
Simon

Just had a quick look...wow! It's going to take some reading. Comments on the comments anyone?

Regards,
Simon

Hi Lion Maru,

Thanks for facilitating this piece of fantastic report. I am hardly half way through reading the comments and it appears that the Big Boys are already hammering it down to the ground which IMO are fairly valid reasons.

I think the Administrator (of course SaferPak not ISO) should park some of these comments for discussions in this forum. Maybe some of these "uncertainties" may become clearer then.

Cheers
Charles Chew

I think the Administrator (of course SaferPak not ISO) should park some of these comments for discussions in this forum. Maybe some of these "uncertainties" may become clearer then.

<{POST_SNAPBACK}>

If you want me to pull out some text from the comments document and post it for discussion that's no problem. It'll be a lot easier to digest in bite size chunks (excuse the pun). Where do you want me to start?

Regards,
Simon

Where do you want me to start?

Well, I guess Lion Maru could give us an idea and if not, we shall leave it to you. Personally, a lot of points were brought up so is choice for grabs really.

Cheers
Charles Chew

Well to be honest I think that the fact that there were so many responses is actually a positive thing - if you look at some of the consultations that FSA put around and the limited responses they get back (mainly because half of the organizations listed in their consultees list don't exist anymore!) then you can see there has been considerbale time and thought put into this work.
I think that, combined with the fact that there were only very few abstentions, missed votes or negatives tells more than some of the actual comments - many of which dwell on vocab or are editorial.

That said I was interested in the GB comment:

"There is no supporting literature with 22000 that provides for assistance with interpreting the standard, gives an understanding of auditor qualifications and experience nor any support for accreditation bodies in deciding on how the standard should be audited to provide consistent application."

and on Australia's point on A.2: 'As for any other management system standard, it is important to stress that the system is certified not products'

So that sounds like EN 45012 right?

How does this fit in with the GFSI requirements that require EN 45011 compliance? Wonder what UKAS's position is now - I note their website hasn't been updated with a stated poistition yet - but there are many Cert bodies(efsis anyone?) who are offering training and proto certifcation to the document

Well to be honest I think that the fact that there were so many responses is actually a positive thing.

<{POST_SNAPBACK}>

Agreed. It's important they get it right (or as right as can be) and it is reasuring to see they're doing the best they can.

That said I was interested in the GB comment:

"There is no supporting literature with 22000 that provides for assistance with interpreting the standard, gives an understanding of auditor qualifications and experience nor any support for accreditation bodies in deciding on how the standard should be audited to provide consistent application."

<{POST_SNAPBACK}>

Very important points. The certification process must be determined upfront to ensure at least a degree of consistency and integrity. Even then as our experience with ISO 9000 Certification proves - there are no guarantees. IMO the CP must be considered as carefully as the standard itself otherwise no matter how good ISO 22000 is it'll be a complete waste of paper.

Any thoughts on how this one will go LM?

Regards,
Simon

Well to be honest I think that the fact that there were so many responses is actually a positive thing

Putting aside the comments on some "clumsy" grammar used which should not have occurred anyway, some of the terminologies used as clarified by some member countries could be misleading. On the same note, I enjoyed comments from Australia, Canada and Japan e.g. Hazards cannot be controlled but risk can be etc.

However, I do find it surprising that at this stage of ISO 22K development that so many uncertainties and opinions remain. Perhaps the first revision wouldtake care of this. McDonalds comments which were direct was very supporting of the standard although the direction coming from Codex Secretariate was different but interesting for thoughts.

IMO ISO 22K would nevetheless prevail.

Charles CHew

Hmm. I think that a lot of the terminology has gone back and forth during the documents development (a reflection on the international nature of the document and the evolution of vocabulary within our industry?)

At DIS stage a whole new group of intersted parties gets a chance to speak up - I wouldn't be suprised to see comments and votes from countries who hadn't previously responded or been involved in the work and that probably adds to the confusion.

The fact that MacDonalds have responded indicates the level of support/interest that this docuemnt has generated. I think it will be intersting to see how its picked up by retailers - if at all - and if there is any follow up work done on SME's to bring them in.

It's always easier to see errors, omissions and opportunities for improvement when the legwork has been done and the mud begins to clear.

Reminds me of an old boss of mine.

With regard to the UK retailers they're all pretty much on board with the BRC Global Standards. Is there any reason for them to show an interest in ISO 22000?

Regards,
Simon

With regard to the UK retailers they're all pretty much on board with the BRC Global Standards.  Is there any reason for them to show an interest in ISO 22000?

<{POST_SNAPBACK}>

GFSI Position attached. I think the UK is in a bit of a unique poistion because its the retailers that control the market where as else where it's the manufacturers

Update on ISO 22000.

Working group 8 - who are developing 22000 met on the 13th, 14th and 15th December 2004 and discussed the various comments submitted on the draft. A follow up meet is due to talk place on the 13th and 14th January 2005 after that the Final Draft should be issued to ISO Central Secretariat for voting.

'Headlines' from the meeting:
· Use of infrastructure and maintenance PRPs and operational PRPs
· Number of "legs"
· Clarification concerning operational PRPs and CCPs
· Validation and verification of PRPs
· Alignment with Codex
· Improvement and simplification of language
· Small businesses
· The concept of risk
· New definitions
· Clause orders in 8
· Keep the standard as a management standard - not a food standard
· The standard should be more process oriented to be consistent with ISO 9001
· Retailer acceptance important
· EU regulation should not be repeated
· More general approach - the standard should be suitable for all kinds of organizations in the food chain
· Annex A - publish a separate document
· Move some text from Annex A to main document if a separate document is published
· New figures


Changes to the following clauses were agreed upon:
· 1 Scope
· 2 Normative references (no changes)
· 4 Food safety management system
· 5 Management responsibility
· 6 Resource management
· 7.3 Preliminary steps to enable hazard analysis
· 7.4 Hazard analysis
· 8 Validation, verification and improvement of the food safety management system (except first sentence of 8.1)

Other clauses will be discussed in Jan. I understand principles have already been agreed on a number of the comments in smaller working groups.

The retailer acceptance of ISO 22000 was discussed. It was mentioned that two out of three key elements are fulfilled according to GFSI requirements (management and HACCP) but requirements concerning GMPs are not sufficient. Drafting technical specifications concerning GMP, GAP etc, may solve this.

The Working Group will be presenting to GFSI in Rome in February.

Besides development of ISO 22000 it was agreed that certification schemes, auditor qualifications etc. should be developed. A first draft for a future work item is being put together.

It was decided that Annex A is to be converted into an ISO Technical Specification (ISO/TS 22002). The content of TS 22002 will concentrate on interpretation of ISO 22000, guidance on how to use it, indirect suppliers of the food chain, small- and medium sized businesses and examples illustrating the flexibility of ISO 22000. Japan is leading the drafting of the TS. The deadline for publication is the same as for ISO 22000 (September 2005).

So a lot of work by the sounds of things - all very positive and we actually now have a date for final publication. I'll keep you informed as I find out details.

Absolutely brilliant! Thank you so much for the update LM.

Regards,
Simon